national multiple family submetering and allocation billing program ...

The National Submetering and Utility Allocation Association (NSUAA) has taken the
positive step of developing a set of self-governing “Best Practices Guidelines for Recovering
Water and Wastewater Costs in Apartment Properties.” Best practices, or best management
practices (BMPs) as they are commonly called, are often issued by trade and professional
organizations to establish a code of conduct and to foster self-governance. Best management
practices are a reasonable start for dialogue with policy makers and can be used to protect the
interests of multi-family dwelling owners, residents, and the public water utilities that serve
them.
Consumer Disputes and Appropriate Recourse
Any system of billing consumers can become a venue for disputes. In the survey of
multi-family property managers, nearly half of the properties that had converted to separate
billing systems reported that there were complaints from residents when the new system was put
in place. Indeed, resistance from residents was the lead difficulty encountered by properties that
converted to separate billing. About equal numbers of the complaints about conversion asserted
that the bills were "too expensive" and that the billing was "unfair".
Of the surveyed residents who said they were dissatisfied with the way they were billed
for water, the leading cause was "accuracy of reported consumption" (46%), followed by the
"rates" themselves (40%). For dissatisfied RUBS residents, accuracy was a cause of complaint
for 55% while rates were of concern to 35%. For dissatisfied submetered residents, 34% were
concerned about accuracy, 44% were concerned about rates, and 54% were concerned about
service charges on their bill. Relatively few in-rent residents reported being dissatisfied with
their billing at all.
One notable finding of the manager survey was the relatively high rate of non-payment of
water and wastewater bills by residents. While 50% of the properties reported non-payment
rates of 1% or less, some 26% of properties with submetering or RUBS reported non-payment
rates of 10% or more. This compares with non-payment rates in the less than 1% to 2% range
typically experienced by water utilities themselves. With this level of dysfunction evident in the
billing environment, appropriate forms of recourse will be essential to protect the interests of
owners and residents alike.
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